On this 20th day of June in the year 1832 personally appears in open court John H Bayne Defendant at the suit of Nelly Lemmon & children petitioners. & made oath on the holy Evangels of Almighty God, that since the trial of the said suit he hath discovered testimony which he deems of the greatest importance to the fairness & justice of his defense in said suit & which he verily believes to be true & was unknown to him before the trial & that on a new trial, it will be in his power to produce cite. That the said newly discovered evidence is to the following aff as follows. That before the trial of the said suit, the said Nelly Lemmon, did offer to We Samuel Webster, the witness examined in said suit the services of one of her children for the use of the wife of said Webster, provided he would give testimony for her to free her & her children in her said suit. That since the said trial the said Webster has said that he had got her from said Nelly Lemmon a negro girl, & that it was all he got for his trouble & services in getting Nelly Lemmon free